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DSCSA small dispenser exemption checker

A quick self-check against FDA's published definition. It runs entirely in your browser; nothing is sent anywhere.

"A dispenser is considered a small dispenser, for the purposes of the exemptions, if, as of November 27, 2026, the company that owns the dispenser has 25 or fewer full-time employees licensed as pharmacists or qualified as pharmacy technicians."
— FDA, Exemptions under the Drug Supply Chain Security Act (content current as of 08/26/2026)

1. Is the business a dispenser under DSCSA (for example a retail, independent, or other licensed pharmacy that dispenses prescription drugs)?

Yes No / not sure

2. Full-time employees licensed as pharmacists, across every location owned by the same company 3. Full-time employees qualified as pharmacy technicians, across every location owned by the same company

"Full-time" uses the IRS definition FDA adopted: on average at least 30 hours of service per week, or 130 hours per month (IRS). Count people, not locations. The count that matters is the one as of November 27, 2026.

How the count works, in plain English

Whose employees: FDA counts at the level of "the company that owns the dispenser" (the letter says "the corporate entity that owns the dispenser has a total of 25 or fewer"). A three-store owner counts all three stores together.
Which employees: only full-time employees licensed as pharmacists or qualified as pharmacy technicians. Cashiers, drivers and other staff are not part of this count. FDA notes the statute says "25 or fewer full-time employees" without that limit, and that its exemption deliberately applies to this broader group of dispensers (letter, footnote 16).
When: the total number of employees as of November 27, 2026 (letter, footnote 14).
"Full-time": FDA adopts the IRS definition: on average at least 30 hours of service per week, or 130 hours per month, for a calendar month (letter, footnote 15).
No paperwork to FDA: "Small dispensers and their trading partners who utilize these exemptions do not need to submit anything to FDA or inform the agency" (FDA).

This checker is a reading aid, not a legal determination. Edge cases (part-time staff averaging close to 30 hours, ownership groups, staff on leave) should be reviewed with counsel or your state board.